On July 29, 2019, CMS released both CY 2020 proposed rulings for the Physician Fee Schedule and Outpatient Prospective Payment System. The proposals echo the messaging that we’ve heard from CMS and the current administration over the past few years with great focus on improved quality of care, price transparency, ease of use, and lowering healthcare costs. National Medical has advocated for many of these changes, meeting with legislators on Capitol Hill to discuss the quality of care provided in ASC. Of note, in the CY 2020 proposed rulings, CMS is proposing to move Total Knee Arthroplasty (TKA) to the ASC-payable list along with 6 additional cardiac codes, amongst others. CMS also proposes moving Total Hip Arthroplasty (THA) off of the inpatient only list, a key proposed change given that movement of total joints out of the hospital setting was not part of last year’s CY 2019 proposed or final ruling. CMS also continues to propose postponement of the OAS CAHPS survey as they evaluate different models for deployment, including a highly desired electronic option. Additional detail of proposed changes to the Physician Fee Schedule and Outpatient Prospective Payment System are discussed below.
Physician Fee Schedule:
- Proposed increase in Medicare Anesthesia conversion factor from $22.2730 to $22.2774. The Resource Based Relative Value System (RBRVS) conversion factor is proposed to increase from $36.0391 to $36.0896.
- New and revised codes for pain procedures, including new codes for sacroiliac (SI) joint and genicular nerve procedures. There are also proposed work and PE RVU changes for certain somatic nerve injections.
- Impact by Specialty: The payment rates are impacted by a range of proposed policy changes related to physician work RVUs, practice expense RVUs and malpractice RVUs. CMS summarizes these changes in Table 110 in the proposed rule. Proposed payment rate changes ranged from -4 percent for ophthalmology to positive 3 percent for clinical psychologists and clinical social workers. The anesthesiology impact was 0 percent and the impact on Interventional Pain Management is estimated as a positive 1%. Actual impact for a practice will vary based on service mix.
For more details visit: https://www.cms.gov/newsroom/fact-sheets/proposed-policy-payment-and-quality-provisions-changes-medicare-physician-fee-schedule-calendar-year-2
Outpatient Prospective Payment System:
- CMS is completing the two-year phase-in of a method to reduce unnecessary utilization in outpatient services by addressing payments for clinic visits furnished in the off-campus hospital outpatient setting. Clinic visits are the most common service billed under the OPPS.
- Proposed Updates to OPPS Payment Rates: In accordance with Medicare law, CMS is proposing to update OPPS payment rates by 2.7 percent. This update is based on the projected hospital market basket increase of 3.2 percent minus a 0.5 percentage point adjustment for multi-factor productivity (MFP).
- Proposed Updates to ASC Payment Rates: Using the hospital market basket, CMS proposes to update ASC rates for CY 2020 by 2.7 percent for ASCs meeting relevant quality reporting requirements. This change is based on the projected hospital market basket increase of 3.2 percent minus a 0.5 percentage point adjustment for MFP. This change will also help to promote site-neutrality between hospitals and ASCs and encourage the migration of services from the hospital setting to the lower cost ASC setting.
- CMS is proposing to remove Total Hip Arthroplasty from the Inpatient Only (IPO) list, making it eligible to be paid by Medicare in both the hospital inpatient and outpatient setting.
- In addition, the Agency is soliciting public comments on the potential removal of the following spine codes from the IPO list: 22633, 22634, 63265, 63266, 63267 and 63268.
- CMS is proposing to add eight codes to the ASC payable list for 2020:
- 27447 Total knee arthroplasty
- 29867 Allgraft implant knee w/scope
- 92920 Prg cardiac angioplast 1 art
- 92921 Prg cardiac angio addlt art
- 92928 Prg card stent w/angio 1 vsl
- 92929 Prg card stent w/angio addl
- C9600 Perc drug-el cor stent sing
- C9601 Perc drug-el cor stent bran
- Additionally, CMS is soliciting comments on how the agency could redesign the role of the ASC-CPL to improve physicians’ ability to determine the setting of care as appropriate for a given beneficiary situation.
- Device Pass-through Applications: There were seven device pass-through applications that were reviewed for the CY 2020 proposed rule. There were no proposals to approve or deny any of the applications in the CY 2020 proposed rule. CMS is soliciting comments before making final determinations on the applications in the final rule.
- Ambulatory Surgical Center Quality Reporting (ASCQR) Program: CMS is not proposing to remove any measures in this rulemaking as our analysis of the current ASCQR Program measure set indicates that there are no measures that meet the measure removal factors following last year’s comprehensive removal initiative. CMS is proposing to adopt one claims-based measure beginning with the CY 2024 payment determination, ASC-19: Facility-Level 7-Day Hospital Visits after General Surgery Procedures Performed at Ambulatory Surgical Centers (NQF #3357).
- CMS is also requesting comment on potential future updates to the submission method for certain patient safety measures for which data collection is suspended: ASC-1: Patient Fall, ASC-2: Patient Burn, ASC-3: Wrong Site, Wrong Side, Wrong Procedure, Wrong Implant, and ASC-4: All-Cause Hospital Transfers/Admissions.
For more details visit: https://www.cms.gov/newsroom/fact-sheets/cy-2020-medicare-hospital-outpatient-prospective-payment-system-and-ambulatory-surgical-center
This post was first published August 2, 2019 and was updated July 29, 2020.